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#2255939 - 06/25/21 01:24 PM Cash exchange CTR
Todd Offline
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Joined: Aug 2020
Posts: 11
We had a bank customer come in with $20,000 in cash in 20's. He exchanged it for $20,000 in $100's. I have two questions on this for filing a CTR. Is it filed as cash in $20,000 and cash out $20,000 and if so is it considered multiple transactions then?

Thanks in advance for your help.

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#2255941 - 06/25/21 01:58 PM Re: Cash exchange CTR Todd
BrianC Offline
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Illinois
It is an in and an out. It is a single transaction.
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#2255954 - 06/25/21 02:58 PM Re: Cash exchange CTR Todd
RockChucker, CAMS Offline
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Agreed
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#2255964 - 06/25/21 03:55 PM Re: Cash exchange CTR Todd
Todd Offline
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Thanks for confirming what I was thinking.

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#2255999 - 06/25/21 08:42 PM Re: Cash exchange CTR Todd
unknown Offline
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What if customer deposits reportable cash in the morning and then withdraws reportable cash in the afternoon? Would this be considered multiple transaction?

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#2256003 - 06/25/21 09:11 PM Re: Cash exchange CTR Todd
rlcarey Online
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Yes
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#2256058 - 06/28/21 06:32 PM Re: Cash exchange CTR Todd
unknown Offline
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Where can I find the latest CTR guidance? Is it the XML User Guide (Version 1.7/July 2020)? Or is there another version after this? We have different opinions on when to select “multiple transactions” box.

Thanks in advance.

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#2256062 - 06/28/21 06:48 PM Re: Cash exchange CTR Todd
rlcarey Online
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https://www.fincen.gov/frequently-asked-questions-regarding-fincen-currency-transaction-report-ctr


18. When do you check the “Multiple transactions” box (Item 3)?
Filers should check “Multiple transactions” (Item 3) if there were multiple cash-in or cash-out transactions of any amount conducted in a single business day by or for the person recorded in Part I. “Multiple transactions” is not the same as the Item 24 option “Aggregated transactions,” which only involves multiple transactions all of which are below the reporting requirements and requires at least one of the transactions to be a teller transaction. The use of Item 24 “Aggregated transactions” is discussed in more detail in FAQ #27.

For example, if Tom Doe deposited $6,000 to his personal account in the morning, and then later in the same business day deposited an additional $5,000 to his personal account, the filing institution would check Item 3 “Multiple transactions” when completing a Part I on Tom Doe. Another example would be if Tom Doe deposited $7,000 into ABC Restaurant’s business account and then later in the same business day Jane Smith deposited $5,000 into ABC Restaurant’s business account, the filing institution would check Item 3 “Multiple transactions” when completing a Part I on ABC Restaurant; however, the filing institution would NOT check Item 3 “Multiple transactions” when completing a Part I on Tom Doe or Jane Smith.

There may be instances where, at one time, an individual brings in funds to deposit to multiple accounts at the financial institution. Whether or not to check “Multiple transactions” in these instances depends on the financial institution’s procedures. For example, a customer brings in $15,000 and deposits the funds to three different accounts; the financial institution posts each transaction individually, choosing as a matter of policy to define each as a separate transaction. When completing Part I on the conductor, the financial institution would check Item 3 “Multiple transactions” as a result of its procedures to post the transactions individually and treat each one as a separate transaction.
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